Peter Black

The consultation on the Plaid Cymru-Labour's Government's badger cull in North Pembrokeshire ends on 17th December. I have set out below my response. Apologies for the length.

Question 1: Do you object to the culling of any wildlife for the purposes of controlling disease in farm animals? *
If yes, please explain why? :

Yes, Firstly, I would like to point out that this is a leading question. The consultation document is only concerned with badgers, a protected species, and therefore questions should only be related to badgers rather than wildlife as a whole. However, by concentrating on the badger this consultation and research into bTB in general fails to look into potential hosts in our wildlife, for example, deer, hedgehogs, moles, as well as feral cats and rats.

Responding specifically to your question, I am against the culling of wildlife for the purposes of controlling disease in farm animals if the disease does not risk human life and there are other ways to control the disease. Before culling is allowed, there should be surety of the wildlife causing the disease in farm animals and due consideration given to other causes of the disease. Relating this question to the detail of the consultation (badgers and bTB), bTB does not risk human life and there are humane methods of controlling the disease other than culling including vaccination and farming methods.

Question 2: In view of the fact that a licence for an injectable vaccine for badgers is now available, do you think that vaccination of badgers in bovine TB endemic areas is a viable alternative to culling to prevent disease transmission? *
If yes, please explain why?

Yes, There is a bank of evidence available which proves that vaccination is viable (and that culling itself does not work) to prevent disease transmission. Most recently, research by VLA (Veterinary Laboratories Agency) and FERA (Food and Environment Research Agency) showed ‘a clear effect of vaccination on badger disease’. It is worth adding at this juncture, that other options are available to control bTB which this consultation does not consider and to add my concern that as all focus is given to badger culling the research and evidence of other methods to control bTB are overlooked. This view is shared by many professionals including a former government advisor Chris Cheeseman who has stated “Because Defra is committed to culling, they're focusing on that and I think they see the vaccination work as a distraction”. I hope that the Welsh Assembly Government can lead the way with a broader vision.

Consideration should be given to the success of vaccination in cattle itself. Historical evidence proves this is successful when Intradermal Tuberculin Testing post war reduced incidents of bTB to residual proportions without any badger culling. As recently as 2008 Defra stated that “many countries have eradicated bTB through the systematic application of the tuberculin skin test alone and the slaughter of all test reactors.”

This leads to a question which this consultation does not address but implies– the evidence that badgers are the cause of bTB in cattle through disease transmission. This historic evidence shows that bTB is spread from cow to cow as occurred post war when badgers (and other wildlife) were no less widespread than they are currently.

The Krebs report of 1997 stated that “The best prospect for control of TB in the British herd is to develop a cattle vaccine”. Such a vaccine has been developed and could be used, however EU law prohibits live export of tested cattle. Consideration should be given to the number of live cattle exported each year and the benefits and costs of this compared to the costs of culling both badgers and herds with bTB.

Question 3: Do you believe that culling badgers can achieve a reduction in bovine TB incidence in cattle, to justify its use? *
If no, please explain why?:

No, There is insufficient evidence to prove that badgers are responsible for bTB incidence in cattle. Evidence shows culling causes perturbation leading to a prevalence of TB in badgers and increased Tbherd breakdowns in boundary areas.

The most up to date and comprehensive research into bTB and badger culling, the Independent Scientific Group (ISG) on bTB have published their findings, stating that culling badgers cannot reduce bTB in cattle ‘to any meaningful extent’ and that perturbation, or disturbance of badger social groups from culling would make matters worse. This is particularly relevant to the proposed order for the Intensive Action Area (IAA) as the natural boundaries are not sufficient to stop badger perturbation.

Question 4: Do you agree that the Intensive Action Area has a high incidence of bovine TB in cattle which needs to be dealt with? *
If no, please explain why?:

Yes. The IAA has a high incidence of bTB which needs to be dealt with but evidence suggests this is not due to badgers but high cattle numbers and low restrictions on cattle movements. As detailed previously, vaccination in cattle is evidenced to be an effective method of dealing with bTB in cattle. TB is a stress related disease which is inevitably linked to modern intensive farming methods.

This is supported by the previously mentioned ISG report stating that cattle spread was the main cause of infection in others, partly due to ineffective control. Professor Borne of the ISG concluded that “rigidly applied control measures targeted at cattle can reverse the rising incidence of the disease, and halt its geographical spread.” May I suggest that you look at the recommendations of the report which detail cattle movements as well as cattle testing and cattle culling. This report repeats the historical evidence regarding bTB control, when the disease was almost eliminated through quarantine and testing, methods which were relaxed at the request of the farming industry.

As mentioned previously, culling badgers in the IAA will simply cause perturbation, so moving the badgers from one area to another.

Question 5: Do you believe that access to land for culling badgers should be enforced? *
Please give reason:

No. This would be an infringement of people’s human rights in our democratic nation. There are farmers against the cull and badgers play a part in their business through tourism. Farmers who wish to vaccinate should be allowed to do so. Forcing such action will lead to divisions within previously peaceful communities and could potentially cause protest and violence within the area. As well as destroying Welsh communities, it would tarnish the reputation of our democratically elected Government here in Wales.

I have concerns that accessing land without consent will lead to risk, as firearms are used for the purpose of culling, and this risk will also exist on rights of way used by the general public.

Question 6: On balance, do you think the benefits of culling outweigh the harm caused to the badger population in the Intensive Action Area? *
Please give reasons for your answer. Would you include other factors in the balance of harm and benefits? If so why?

No. The many points above, scientific and historical evidence provided, confirms that there are no benefits to culling badgers, as the impact on incidences of bTB in cattle is minimal, whilst other methods can be far more effective.

There are many other factors which should be considered, which this consultation fails to address.

Badgers are a protected species and have a role to play in our environment and food chains. No one can deny the stress having bTB in a herd must cause farmers, but the stress caused to landowners opposed to the cull and potentially forced to allow access must also be considered. The consultation fails to consider the impact on the tourism industry from the cull and associated financial costs to them. Although we do not have specific data for badger tourism in Wales, the Wales Visitor Surveys of ‘day and staying visitors’ for the period April- October 2009 revealed that 52% of ‘day visitors’ felt it was very important for a destination to conserve its wildlife and plants and 37% felt it was quite important. Similarly 58% of ‘staying visitors’ thought it was very important for a destination to conserve its wildlife and plants and 36% thought it was quite important. The contribution of wildlife to the Welsh Economy is valuable and should also be considered in any decision of harm and benefits.

Ultimately, the figures do not add up. The cost of culling badgers outweighs the benefits to cattle herds and indeed, the cost of compensation for cattle farms. The September 2010 Submission of evidence states that the cost of culling badgers is £4250 per km sqr. per year, totally £6,120,000 for 5 years (not the £4,590,000 stated, which I can only assume is a mathematical error). The cost of preventing the 83 breakdowns anticipated through this cull, according to this submission is £4,463,503. Therefore the cull will cost more than the estimated savings. I would like to note that the evidence provided with the consultation fails to provide the detail, to enable us to test the validity of the figures provided. These figures do not take into account the cost to the tourism industry noted above and ancillary costs such as policing.

Question 7 : Do you agree with the prohibitions under the draft Badger (ControlArea) (Wales) Order 2010? *
If not, why not?:

No. The prohibitions in the draft order are excessive and restrict civil liberties. It puts pressure on people who previously lived harmoniously in our communities to take ‘sides’ despite the science available. Worryingly, it sets a precedent for how we should treat our wildlife and those who aim to protect it, with brutality.

We have asked a number of specific questions. If you have any related issues which we have not specifically addressed, please report them separately in your response. :

The possibility of shooting badgers free range, rather than in a cage is of concern. This could cause severe distress and pain to an animal, as a moving target. This also presents a risk for the landowners and other land users.
My main concern is that this decision should be based on science, not politics. The ISG took 9 years and cost £49 million, we should not ignore the evidence it provides us with. In my opinion, a badger cull simply puts a sticking plaster on the issues destroying a protected species, instead of dealing with the cause of the problem.

Finally, I have completed many consultations both at local, Welsh and UK Government levels and have found this consultation to be very leading in both the evidence (and lack of) that it has provided and the questioning. I hope the responses given and evidence referred to will be considered objectively.